TLDR: A company is taxable in France if it carries out regular commercial activity, has a permanent establishment, or conducts real estate transactions, even without a permanent physical structure. Specific rules apply to EU/EEA companies.
Regular Commercial Activity
A foreign company is subject to corporate income tax (CIT) in France if it conducts regular commercial activity on French territory. This includes repeated or organized operations, such as collecting advertising orders from French clients or financial transactions (loans, guarantees).
Permanent Establishment
The presence of a permanent establishment in France, such as a branch, office, or operational center, makes a foreign company taxable. This also includes fixed places of business where the company carries out all or part of its activity.
Real Estate Transactions
A foreign company that owns and rents commercial or residential properties in France is subject to CIT on rental profits, regardless of whether it conducts regular commercial activity or has a permanent establishment.
EU/EEA Companies
Companies established in the European Union (EU) or the European Economic Area (EEA) may avoid the application of deemed profit distribution if they are subject to effective taxation in their country of residence and reinvest profits in France.
Exclusions and Limitations
Intra-group financial transactions, such as interest or royalties paid by a French branch to a foreign parent company, are not deductible if they derive from the foreign company's own funds.